FR
English (CA)Modern Slavery Report
FINANCIAL YEAR 2024F (May 1, 2023 – April 30, 2024)
STELPRO DESIGN INC.
This Modern Slavery Report (the “Report”) covers the period from May 1, 2023, to April 30, 2024, and has been prepared in accordance with Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Act”). This Report is submitted on behalf of Stelpro Design Inc. (Stelpro).
Introduction
Forced labour and child labour, as defined by law, are crimes and serious violations of human rights. As a leading company in the heating industry, Stelpro recognises the important role we play in ensuring that our operations and products, and the supply chains that support them, meet the highest ethical standards, including the prevention and identification of forced and child labour in our supply chain. This report describes the measures we have taken during fiscal year 2024 (May 1, 2023 – April 30, 2024) to prevent and mitigate the risk related to the use of forced labour or child labour at any stage of the production of goods by Stelpro, in Canada or elsewhere, or their importation into Canada by Stelpro.
Our company
Stelpro is a family business established in Quebec for 40 years and recognized in the electric heating, heating cables, ventilation (HVAC) and electronic controls industries. A North American leader in its sector, it offers quality heating products designed and manufactured in Quebec that combine optimal performance, safe use and innovative design. The company serves the residential, industrial, commercial and institutional construction and renovation markets. In total, more than 500 qualified people work to make Stelpro the flourishing company it has become. Thanks to its employees, Stelpro is constantly innovating by improving its current products and developing new ones that meet its customers’ needs.
Our supply chain, from which we source the materials, components and products that go into the manufacture and distribution of heating products, includes companies that provide goods and services to our organisation, and is made up of around one hundred suppliers from around the world.
You can find out more about our activities on our corporate website.
Our policies
Through our organisational and governance policies, we communicate our values and expectations to our employees, suppliers and sales partners, indicating that we aim to ensure that the rights and obligations of all are respected. We are committed to constantly evolving and improving our approach. We do not tolerate child labour, forced labour or bonded labour in any of our operations or by suppliers working for us. We make every effort, including exercising due diligence and carrying out audits to monitor the performance of our suppliers, to ensure that our activities do not have a negative impact on human rights. Our policies in this area are discussed in more detail below:
Code of conduct and ethics
We are committed to conducting our business in a fair, legal and ethical manner. Our Employee Handbook contains a Code of Conduct which sets out guiding principles for business conduct and states that, in carrying out their duties, Stelpro employees must always act legally, ethically and in the best interests of Stelpro. All our recruitment procedures comply with applicable local regulations and standards, and we take a fair and equitable approach to the search for talent. Salaries comply with local laws and regulations and are governed by internal pay equity for professional employees and by a collective agreement for employees working in our factory. Stelpro also advocates freedom of work, which means that all work must be done voluntarily. No employee should be forced to work against their will. Our employees may terminate their employment by giving the required contractual or statutory notice at any time. Child labour and the employment of children under the legal minimum age are strictly prohibited at Stelpro.
Supplier Code of Conduct
Stelpro’s Supplier Code of Conduct details the requirements and expectations we have of the suppliers we work with. We expect our suppliers to comply with all applicable legal requirements in the jurisdictions in which they operate and to systematically monitor and apply our Supplier Code of Conduct in their own operations and supply chain. Our Supplier Code of Conduct also sets out our principles of inclusion and responsibility. We work with suppliers who adhere to these same principles, and suppliers commit to meeting these standards as a condition of doing business with us.
Due diligence
We expect the third parties we work with to adhere to similar business principles and values to our own and to comply with all applicable laws and regulations. Before entering into commitments with third parties, we take steps to properly assess the relationship and mitigate the associated risks through risk-based due diligence and verification. We recognise that employees working in our facilities and supply chain are exposed to a potential risk of forced or child labour. To mitigate this risk, we follow a due diligence approach by:
- Developing close relationships with our main suppliers;
- Visiting our suppliers;
- Carrying out third-party audits when selecting new suppliers;
- Working with manufacturing agents who provide local liaison with suppliers based internationally.
Assessing our risk
Stelpro demonstrates its commitment to ensuring that its suppliers do not use modern slavery or child labour. Through our commitment to enforcing our codes of conduct with our employees and suppliers, as well as the various measures taken throughout our supply chain listed above, we believe that there is a minimal risk that Stelpro is contributing to or is linked to modern slavery and child labour. However, Stelpro recognises that due to the unavoidable realities of our complex global supply chain, we may, in some cases, be indirectly exposed to the risks of modern slavery. Our exposure to the risk of forced labour and/or child labour increases when we work with suppliers located in countries that may present a higher risk of modern slavery.
Our commitments and progress
Over the last financial year, Stelpro has further committed to the fight against modern slavery and child labour in its supply chain by drafting a supplier code of conduct. The measures that exist at Stelpro to eliminate the use of forced or child labour in our operations and supply chains do not result in loss of income for vulnerable families.
Remedial measures
Our Code of Conduct (Employee Handbook) and Supplier Code of Conduct require all employees and suppliers to report any actual or potential misconduct. We also undertake due diligence efforts (as described in more detail in this report) to ensure that the risk of forced labour and child labour is mitigated in our business. In the event that we discover forced labour or child labour in our facilities and supply chains, we will ensure that sanctions, as set out in the Codes, are applied commensurate with the severity of the misconduct.
Training
Each new Stelpro employee must read and sign the Employee Handbook, which includes our Code of Conduct.
The employees concerned have been trained in the Supplier Code of Conduct. All new employees will also receive training during their induction period.
Our progress and efficiency
We review all concerns raised through our employee relations committees, supplier audits, supplier feedback or other informal employee feedback mechanisms. To date, no significant concerns or complaints have been identified.
Approval and signature
This report was approved by STELPRO DESIGN INC. on May 20, 2024, and has been submitted to the Minister of Public Safety and Emergency Preparedness of Canada. This report is also available on our corporate website at www.stelpro.com.
In accordance with the requirements of the Act, and in particular section 11 thereof, I certify that I have examined the information contained in this report for STELPRO DESIGN INC. To the best of my knowledge, information and belief, and having exercised due diligence, I certify that the information contained in this report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year referred to above.
François Séguin
Vice-President – Operations and Human Resources, May 20, 2024
I have the power to bind STELPRO DESIGN INC.